Supreme Court of Delaware

Thompson v. State

July 24, 2018

Summary

The Supreme Court of Delaware affirmed the finding that Thompson violated probation. It held that the late disclosure did not warrant reversal because Thompson neither requested a continuance nor showed prejudice, and the trial court remedied any alleged incompleteness by limiting the State's evidence to disclosed material. The court also held that the exclusionary rule does not apply in probation-revocation proceedings under the federal Constitution, waived the separate state-constitutional argument, and found sufficient evidence of a violation. Justice Seitz concurred, stating that possible constitutional issues in probation proceedings were not adequately presented.